Question

Which is the landmark case which expanded the scope of Article 23 of the Constitution of India?

• A. Vishaka v. State of Rajasthan
• B. PUDR v. Union of India
• C. M.C. Mehta v. State of Tamil Nadu
• D. Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut

Hint:

Remember the association: PUDR Case $\rightarrow$ Forced Labour $\rightarrow$ Article 23 $\rightarrow$ Minimum Wage Protection.

Answer 1

The Correct Option is B

Step 1: Article 23 of the Constitution prohibits traffic in human beings, begar, and other similar forms of forced labour, and the question asks which case stretched what forced labour actually covers.

Step 2: Before this case, forced labour was understood mainly as physical compulsion, someone being made to work against their will through threats or coercion.

Step 3: In People's Union for Democratic Rights v. Union of India, the Supreme Court examined workers on Asian Games construction sites who were paid less than the minimum wage, and held that being forced by poverty to accept sub-minimum wages is itself a form of forced labour under Article 23, since the worker has no real choice.

Step 4: That shift, from requiring physical coercion to also recognising economic compulsion, is what makes this the case that expanded Article 23, unlike Vishaka, M.C. Mehta v. State of Tamil Nadu, or Glaxo Laboratories, which deal with sexual harassment, child labour under Article 24, and ordinary labour court disputes respectively.
\[ \boxed{\text{PUDR v. Union of India}} \]

Answer 2

A quick way to sort through these four cases is to tag each one with the single legal theme it is most associated with, and see which theme actually matches Article 23.

1. Vishaka v. State of Rajasthan: tags to workplace sexual harassment and guidelines for women's safety at work, a theme rooted in Articles 14, 15 and 21, not forced labour.
2. PUDR v. Union of India: tags directly to forced labour and minimum wages, since the entire dispute was about whether paying construction workers below the minimum wage amounted to compelling them to work against their will. That theme is precisely what Article 23 addresses, and the judgment is the one credited with reading economic compulsion into the meaning of forced labour.
3. M.C. Mehta v. State of Tamil Nadu: tags to child labour in hazardous occupations, a theme governed by Article 24 rather than Article 23.
4. Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut: tags to industrial dispute and labour court procedure, an ordinary labour law theme with no constitutional expansion of Article 23 involved.

Sorting the four cases by theme leaves only one of them actually addressing forced labour under Article 23, and that is the case that broadened its scope to cover economic compulsion.

Hence, the correct answer is Option B: PUDR v. Union of India.